NYISO on Monday shared a proposal to set a 10-kW minimum capability requirement for individual distributed energy resources participating in aggregations, which it said would help support their integration in its markets.

The ISO is developing new software and internal procedures to comply with FERC Order 2222, which did not set any minimum requirements for DER deployment. But NYISO said the work generated more overhead costs to interconnect DERs.

NYISO said that its proposal, presented to the Installed Capacity Working Group, would help staff save time reviewing aggregations for interconnection: reviewing 100 1-kW DERs in an aggregation would take significantly more time than reviewing an aggregation of 10 10-kW DERs, though both would have the exact same capacity.

The ISO said the minimum requirement would enable aggregations to remain flexible and still deliver their services in a reliable and timely manner, but also allow staff to catch up on the compliance work.

It also said it would consider lowering the minimum after market deployment has been underway for some time and it has gained experience managing DER aggregations.

Stakeholders attending the meeting expressed concern about the proposal, saying it could disenfranchise entire residential market classes from being included in aggregations, and that it would not supply the experience NYISO is looking for because most initial aggregation participants will be on a larger scale (20 to 40 kW).

NYISO intends to file the proposal with FERC toward the end of 2022. Comments or questions should be sent to DER_Feedback@nyiso.com.